Helping you comply with regional emission control requirements

Sulphur emissions from ships are governed by an increasing number of regulations, from those established under MARPOL Annex VI (within SOx Emission Control Areas) to those specified in EU Directive 2005/33/EC and by bodies such as the California Air Resources Board (CARB).

We can help you ensure compliance with these requirements. Our Fuel Change-over Plan provides step-by-step procedural guidance covering all aspects of change-over to low-sulphur fuel, data recording and documentation.

Meeting the emissions challenge

Within the SOx Emission Control Areas (SECAs) specified under MARPOL Annex VI, fuel sulphur content must not exceed 1.5% m/m. This limit will reduce even further during 2010 and SECA locations will be extended in the future, presenting major challenges to ship operators. In addition, other Sulphur Limited Zones (SLZs), each with their own fuel oil sulphur limits, have been, or will be, established by bodies such as the EU and CARB.

Demonstrating compliance

Demonstrating compliance for ships which operate exclusively inside or outside SLZs is relatively simple, since fuel should be compliant. For ships which operate across SLZ boundaries, however, it is more complicated.

Unless they are using an approved exhaust gas cleaning system, or other alternative equivalent arrangement, operators must demonstrate that the ship has changed over from high-sulphur fuel oil (HFSO) to low-sulphur fuel oil (LSFO) before entering an SLZ. They must also demonstrate that it has not used HSFO before exiting the area.

How can we help?

We can help you demonstrate compliance with SLZ requirements. Our Fuel Change-over Plan provides step by- step guidance on the fuel change-over procedure to the ship’s crew.

We can carry out an optional verification survey and issue a certificate stating that the Fuel Change-over Plan is being satisfactorily implemented in accordance with regulations. Verification will provide assurance that the change-over procedure is being followed.

What does the plan contain?

The Plan is a shipboard manual which provides a record of the ship’s equipment, fuel tank arrangements, fuel capacities and equipment data, together with a list of actions to be taken in each operational mode when entering or leaving an SLZ. It covers all potential scenarios and provides clear instructions and safety guidelines to help ensure a safe and controlled change-over process.

The Plan simplifies the inspection and verification of the change-over procedure by inspectors and surveyors, and helps you easily demonstrate compliance.

Along with each Plan, we also provide a copy of our Marine Fuel Sulphur Record Book, which is endorsed by the UK’s Maritime and Coastal Agency (MCA). This is designed to capture the operational information needed to demonstrate that the change over to LSFO complies with the area requirements.

Factors affecting change-over

Fuel change-over needs to ensure that the fuel’s sulphur content meets the particular SLZ requirements from the time of entry to the point of exit. Attention must be paid to: sulphur content; consumption; and the fuel tank arrangement.

Fuel sulphur content

During change-over, high-sulphur fuel is mixed with low-sulphur fuel. The time needed for the change-over is calculated on the basis of a complete linear blend. This calculation is done using our Low Sulphur Fuel Oil Change-over Calculator, included in the Plan.

Fuel consumption

Fuel tank arrangement

The configuration of fuel tanks also affects the duration of the change-over. A fuel tank arrangement which consists of one settling tank and one service tank will take longer to flush than one which consists of two settling and two service tanks. For ships with separate low and high-sulphur fuel tanks, the change-over period will be very short.

Other factors

There are a number of other factors that can influence change-over time, such as: the length of piping between the service tank and the engine; the volume of the mixing tube; and the fuel heater.